USAC’s Schools and Libraries Division hosts monthly service provider conference calls, providing information and guidance for vendors participating in the E-rate program. Highlights from October 3 service provider call include:
September 2012 Commitments
Since the last call, USAC has approved the following funding commitments:
FCC Form 498 Update
The Office of Management and Budget (OMB) will be approving a new Form 498 within the next few weeks. On the new Form 498, a service provider can designate a separate E-rate bank account for BEAR disbursements. Service providers will not need to file a new Form 498 unless their contact information changes.
Update on Fall Applicant Training
On September 28, 2012, USAC published the training materials that will be used in their fall applicant training sessions. The sessions include Understanding the Basics, State of E-rate, Eligible Services, Program Compliance, Audit Readiness and Success, Myths and Misconceptions Debunked, and Changes and Corrections.
Payments for the month of September totaled $206.6 million, against $259.9 million in requests. Invoices were submitted by 1,698 service providers, and 96 percent were processed within 30 days.
Update on New Form 470 Download Tool
The SLD will be releasing a new Form 470 Download Tool in the coming weeks. Enhancements include new search options based on date range, state(s), category of service, or applicant type.
Assume prior to submitting a Form 470 the applicant seeks information from a variety of sources, including the service provider community. One service provider tells the applicant “Our system of switches and routers are ideal for you. They are cost effective, highly reliable, have an excellent warranty, and include automatic compression techniques for improved performance.” If the applicant independently decides that warranty and reliability are important factors, are they precluded from including them in their bid evaluation criteria because that would be viewed as undue influence from a service provider?
SLD Answer: Applicants can have the ability to select their own evaluation criteria and applicants can talk to companies about their product offerings in advance of the competitive bidding period.
We received the following request from our applicant regarding our P1 telco/WAN network equipment:” Kindly provide the following information as needed for conducting program audits and meeting reporting and accountability requirements regarding funding and service delivery. (1) IP address of all radios and all core routers at the back bone and site locations (2) SNMP data (username, password) to gain read-only access to those devices.” Certainly we want to be in compliance for audits and reporting, but this violates fundamental network security practices. We provide WAN utilization statistics monthly. Must we also provide our applicant with the IP addresses and login to our network equipment? Is this a common practice for large carriers such as AT&T to provide this network login information to their ERate customers? Your guidance is much appreciated.
SLD Answer: These are not E-rate audit requirements and are not subject to FCC E-rate document retention policies
What are the timeframes for receiving notification about SPIN changes?
SLD Answer: There is a backlog of SPIN change requests, both corrective and operational, but the SLD is hopeful to have the backlog cleared in the coming weeks
Note: The information above is not the official minutes from the call, but simply notes from Funds For Learning. The official minutes for this call, as well as call minutes from previous months, can be found here.